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A family group requested clarification on whether contributing shares to holdings, followed by a share swap and a subsequent merger, could qualify for the special regime under the Corporate Income Tax Act. The DGT ruled that if technical requirements are met and the objectives are group rationalisation and simplification, the operations are valid.
Companies undertaking restructuring must ensure that transactions are driven by genuine economic rationalisation rather than purely tax-driven motives to qualify for the special tax regime.
The tax team reviews your specific situation.
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